What the auditor wants to verify
Audit objective
Verify that masking, pseudonymisation, tokenisation, or anonymisation is defined, applied, access-controlled, legally appropriate, and protected against unauthorized re-identification.
Evidence to request
| Evidence | Purpose |
|---|---|
| Data masking standard | Shows masking methods and rules are defined |
| Sensitive data inventory | Shows data requiring masking is known |
| Data masking decision register | Shows masking decisions are justified |
| Role access matrix | Shows who may view full data |
| Masking configuration/demo | Shows technical implementation |
| Lookup table/key segregation evidence | Shows re-identification path is protected |
| Re-combination logs | Shows full-data restoration is controlled |
| Re-identification risk assessment | Shows potentially identifiable data is assessed |
| Deletion records for re-combined data | Shows full data is removed after use |
Strong evidence
- Masking methods are defined and matched to use cases.
- Full-data access is role-based and approved.
- Token lookup tables/keys are segregated.
- Re-combination is logged and authorized.
- Potential re-identification is assessed.
- Re-combined data is deleted when no longer needed.
Weak evidence
- “Anonymised” data can be re-identified.
- Token lookup table is stored beside tokenized data.
- Developers use unmasked production data.
- Re-combination is not logged.
- Full-data roles are undefined.
Sample interview questions
- Which masking methods are used?
- Who can view full unmasked data?
- How is re-combination authorized and logged?
- Where are lookup tables or keys stored?
- How do you test whether anonymised data is still identifiable?
Common nonconformities
- Masking method not defined.
- Pseudonymised data treated as anonymous.
- Lookup table not segregated.
- Re-identification risk not assessed.
- Re-combined data retained after use.
Related notes
- Audit
- Evidence
- A8 11
- Iso27001
Note Metadata
Aliases: A.8.11 Evidence
Source: 04 Audit Evidence Packs/A.8.11 Audit Evidence Pack.md
Graph-sourced resources
Templates and evidence
Auditor evidence packs
Evidence collections and audit-facing verification material.